PRIVACY POLICY

 Effective Date: January 01, 2020 

This Privacy Policy describes how Northgate Gonzalez, LLC, Northgate Gonzalez Financial, LLC, and their affiliates (collectively, “Northgate”) collect, use, disclose, and protect your personal information.  It also contains legal disclosures, information regarding your rights concerning your personal information, and contact information for Northgate for matters related to your personal information.     

CONSENT TO PRIVACY POLICY

When you access a Northgate website, use a Northgate mobile application, or provide personal information to Northgate by any means, you agree to the terms of this Privacy Policy. 

Special offers, promotions, contests, or specific services might use or require different personal information practices than are described in this Privacy Policy.  If so, those practices will be identified in the specific materials related to those offers, promotions, contests, or services.  

CATEGORIES OF PERSONAL INFORMATION COLLECTED

Northgate has collected or may collect the following categories of personal information:

  • Identifiers
  • Characteristics of protected classifications under California or federal law
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • Biometric information
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)
  • To the extent not covered by another category listed above: name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, financial information, medical information, or health insurance information
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes 

The personal information Northgate collects may (i) include personal information or data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, (ii) involve the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, and (iii) include data concerning health or data concerning a natural person’s sex life or sexual orientation. 

SOURCES OF PERSONAL INFORMATION

Northgate has collected or may collect personal information from the following sources:

  • Directly from consumers, including when you register as a user of one or more of Northgate’s websites or applications, shop online or in Northgate’s stores, sign up for or use Northgate’s products or services, enroll in a marketing programs, cash a check, or contact Northgate.
  • Automatically through Northgate’s websites, and applications, which may include cookies, web beacons, and similar technologies.
  • Security cameras when you are at Northgate’s facilities.  
  • Third parties who provide Northgate with goods or services to help Northgate operate its businesses. 
  • Third parties whose goods and services Northgate directly or indirectly offers or promotes.

Northgate may use cookies, web beacons, and similar technologies in connection with its websites, mobile applications, and email messages. 

SHARING OF PERSONAL INFORMATION

Northgate has shared or may share personal information with the following categories of third parties:

  • Third parties whose goods and services Northgate directly or indirectly offers or promotes.
  • Third parties who provide Northgate with goods or services to help Northgate operate its businesses. 
  • Professional advisors and consultants.  
  • Governmental authorities.
  • Participants in legal proceedings. 

Your personal information may be disclosed as part of an actual or proposed corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. 

PURPOSES FOR COLLECTING PERSONAL INFORMATION

Northgate has collected or may collect personal information for the following purposes:

  • Communicating with consumers.
  • Providing consumers with goods and services.
  • Marketing or advertising goods and services.
  • Verifying consumers’ identities.
  • Keeping records of activities.
  • Conducting statistical, demographic, and other analysis.
  • Monitoring and analyzing trends, usage, and activities.
  • Conducting market research, surveys, and similar inquiries.
  • Preventing, investigating, or providing notice of fraud, unlawful activity, or unauthorized access to or use of information, websites, or data systems.
  • Complying with applicable law or meeting legal obligations.
  • Engaging in legal proceedings.
  • Collecting debts.
  • Satisfying contractual obligations.
  • Assisting law enforcement or other government agencies.
  • Personalizing consumers’ experiences.
  • Entering consumers into sweepstakes and promotions. 

Northgate may link personal information (such as your name or e-mail address) with non-personal information (such as the unique identifier associated with your computer or mobile device). Northgate may also link personal information with other generally or publicly available information to help it identify your preferences or interests. The information Northgate collects may also be merged with information available from other sources such as (1) companies that match e-mail addresses with postal addresses and other information; (2) credit card verification and credit services; and (3) Northgate’s affiliates. 

SELLING OF PERSONAL INFORMATION

For purposes of this Section, “sell” has the meaning provided for under California Civil Code Section 1798.140(t).  Northgate does not sell any personal information.  Accordingly, Northgate does not sell the personal information or minors under 16 years of age without affirmative authorization.  

PERSONALLY IDENTIFIABLE INFORMATION

For purposes of this Section, “personally identifiable information” has the meaning provided for under California Business & Professions Code Section 22577(a).  Northgate collects the categories of personally identifiable information set forth in the Section above entitled “Categories of Personal Information Collected” and may share personally identifiable information with the categories of third parties set forth in the Section above entitled “Sharing of Personal Information.” 

Northgate’s websites do not respond to “do not track” signals or similar mechanisms. 

Northgate is not a part of a third party tracking network and does not allow third parties to collect personally identifiable information about consumers’ online activities through Northgate’s website. Northgate may also allow third parties to serve ads on its websites and applications, and if you visit those third parties’ websites, they may collect information about your visit or use. This Privacy Policy does not apply to the practices of third parties that collect your personal information. Northgate encourages you to check the third parties’ privacy policies to learn about their practices concerning their collection, use, disclosure, and protection of your personal information.

 Except as provided in the Section below entitled “Your Rights Regarding Personal Information After Collection,” Northgate does not maintain a process for an individual consumer who uses or visits its website, application, or online service to review and request changes to any of his or her personally identifiable information.  

YOUR RIGHTS REGARDING PERSONAL INFORMATION AFTER COLLECTION

You have the right to request that Northgate disclose to you: the specific pieces of your personal information that it collected, the categories of your personal information that it collected, the categories of third parties (recipients) to whom Northgate provided your personal information, the business or commercial purpose for processing, collecting, or selling your personal information, the sources from which Northgate collected your personal information, the existence of your rights of access, rectification, deletion, and portability regarding your personal information, your rights to restrict or object to processing, and to complain to a supervisory authority concerning, your personal information, Northgate’s retention period for your personal information, and any automated decision-making, including profiling, made using your personal information.

You have the right to request that Northgate delete the personal information it has collected regarding you and that it require its service providers to do so as well.  However, Northgate have no obligation to comply with your request if there is a legal basis for the processing of your personal information, including: 

  • You have consented to the processing.
  • The processing is for purposes of initiating or fulfilling a contract with you, including completing transactions and providing goods and services.
  • The processing is necessary to comply with Northgate’s legal obligations, including under the California Electronic Communications Privacy Act.
  • The processing is necessary to protect Northgate’s interests or the interests of third parties, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity (or prosecuting those responsible), debugging to identify and repair functionality errors, exercising or ensuring the right of another to exercise free speech or another legal right; or to enable solely internal uses aligned with a consumer’s expectations given their relationship with the business. 

You have the right to require that Northgate correct erroneous personal information it has collected regarding you. 

As stated above, Northgate does not currently sell personal information.  If Northgate changes its policies or practices regarding the sale of personal information, you will have the right to opt-out of Northgate’s sale of your personal information. 

You may have the right to receive a copy of your personal information in a structured, commonly used, machine-readable format and to have your personal information transmitted by Northgate to another controller without hindrance from Northgate.   

You have the right to withdraw, in whole or in part, any consent you have given to Northgate regarding the processing, collection, use, storage, disclosure, and sale of your personal information. 

You have the right to object to the processing of your personal information.  If you object, Northgate will only process your personal information if it can prove it has compelling legitimate reasons for doing so that outweigh your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.  

If you believe that the processing of your personal information violates legal requirements, you have the right to lodge a complaint with a competent data protection supervisory authority. 

You can control the marketing communications you receive from Northgate by updating your profile through a Northgate application, clicking the “unsubscribe” link in Northgate emails, or contacting Northgate using the information below. 

Note that there may be a delay between the time you make an opt-out, removal, or revocation requests and the time it is processed by Northgate.  

You may make requests under this section by calling (888) 672-9832 or sending an email on privacy@northgatemarkets.com. Requests will be acknowledged within 10 days. Northgate will review each request and then contact the person making the request for verification purposes. The verification process will vary depending on who is making the request (e.g., the consumer versus an agent of the consumer), the nature of the request (e.g., categories of personal information versus specific pieces of personal information), and the consumer’s interactions with Northgate. The person making the request may be required to provide personal information about the particular consumer so that Northgate may match that information against its records. If a consumer uses an agent to make a request, Northgate may require the consumer to provide the agent with written permission to make the request and verify their own identity directly with Northgate. The verification process may be accomplished by telephone, via text message, using email, and/or through other electronic means such as a password-protected account through Northgate. Northgate reserves the right to deny requests in whole or in part to the extent permitted under applicable law, including if it cannot verify a consumer’s identity with the required degree or certainty or in good faith suspects fraudulent or malicious activity concerning the request. Northgate will respond to requests within 45 days, subject to extensions of up to an additional 45 days for which the consumer or its agent will receive notice and an explanation for the reasons the extension is required.        

FINANCIAL INCENTIVES

Northgate offers coupons and similar discounts and benefits through its marketing program. These items may be considered a “financial incentive” or result in a “price or service difference” under the regulations to the California Consumer Privacy Act.  The categories of personal information that are implicated by Northgate’s marketing program are:

  • Identifiers;
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement;
  • Geolocation data; and
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

You can opt-in to the financial incentive or price or service difference by contacting Northgate using the methods identified in the “How to Contact Us” section below.  You can withdraw from the financial incentive at any time by using the methods identified in the “Marketing Choices and Opt-Out” section below.  The financial incentive or price or service difference that may result from participating in Northgate’s marketing programs would be permitted under the California Consumer Privacy Act because, based on industry knowledge and sales trends related to Northgate’s historical marketing practices,  Northgate expects to receive more in annual revenue from a consumer who participates in Northgate’s marketing program compared to a similar consumer who does not participate.  Northgate in good faith estimates that this difference in annual revenue will be at least $5.00, but it does not use loyalty cards or similar methods that would allow it to accurately track revenue relative to participation in its marketing program at an individual consumer level. 

INFORMATION PERTAINING TO CHILDREN

Northgate is the only operator of its website, and its contact information is listed in the “How to Contact Us” section below. Northgate does not knowingly or intentionally collect personal information from children under the age of 16, and has taken steps to avoid doing so through its website. Accordingly, Northgate does not enable children to make their personal information publicly available, knowingly or intentionally use their information in any manner, or knowingly or intentionally disclose their information to anyone. If a child under the age of 16 has or may have provided personal information to Northgate, a parent or guardian may inform us of that fact by contacting us using one of the methods listed in the “How to Contact Us” section below, and Northgate will then review its records and delete any such information from its database. If you are under the age of 16, do not provide Northgate with any personal information either directly or indirectly (e.g., by posting personal information on Northgate’s website). Any personal information that Northgate receives from a person whom it believes is under the age of 16 will be deleted. 

SECURITY OF PERSONAL INFORMATION

Northgate uses various physical, electronic, and procedural measures to protect your personal information from unauthorized disclosure or misuse. Northgate employ Secure Sockets Layer (SSL) technology and other security measures to encrypt sensitive personal information you input, such as credit card numbers, during transmission. However, because no data security systems are completely secure, Northgate does not warrant that any personal information that you provide to it will be secure or safe from unauthorized access. If you provide any personal information to Northgate, you do so at your own risk. Northgate may retain your personal information for as long as permitted by applicable law.  Northgate may transfer your personal information to and use and store your personal information in any location.  Northgate is based in the United States.  When you interact with Northgate, your personal information may be transferred to a country other than your own, including the United States.  Data protection rules of other countries may be different from those of your country. Certain locations may not provide safeguards for your personal information, creating risks that it will be disclosed to or used by third parties in a manner that may be harmful or objectionable to you.  Courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal information.  Any collection of personal information will be made in accordance with all applicable laws.  For example, Northgate will not obtain a credit report without first obtaining your specific and express authorization for us to do so.     

LINKS TO OTHER WEBSITES

Northgate’s website may contain links to websites operated by third parties. Northgate may, from time to time, at its sole discretion, add or remove links to other websites. These links are provided solely as a convenience to you, and access to any such websites is at your own risk. Your business dealings, communications with or participations in promotions with advertisers (other than Northgate) and any terms, conditions, warranties or representations associated with such dealings are solely between you and those third parties. When you visit their websites, they may collect information about your visit and use it to provide advertisements to you. 

SOCIAL NETWORK WEBSITES

By accessing the links to certain social network websites posted on Northgate’s website, application, or service, you may have interactions that you initiate with Northgate on those third party websites, applications, or services. Examples of such interactions include enabling you to transmit content from your account on a third party website, application, or service; to “like” or “share” Northgate’s content to other websites, applications, or services; and to otherwise connect Northgate’s website, application, or service to a third party website, application, or service.

Information you post or to which you provide access on such third-party websites and services may be publicly displayed on Northgate’s or a third party’s website, application, or service. Similarly, if you post information on a third party website, application, or service that references Northgate’s website (e.g., by using a hashtag associated with Northgate in a tweet or status update), your post may be published on Northgate’s website or social network websites in accordance with the terms of the third party website or service. Also, both Northgate and the third party may have access to certain information about you and your use of Northgate’s website and the third party site or service.

The information Northgate collects in connection with its social network websites (e.g., Northgate’s Facebook page) is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy practices. 

MARKETING CHOICES AND OPT-OUT

Northgate may send you email messages, direct mail offers, or other communications regarding products or services unless you specifically ask it not to do so when you enroll in its marketing program, access its website or application, or change your preferences by updating any accounts you may have with Northgate. At any time, you may elect to discontinue receiving commercial messages from Northgate by submitting an opt-out request to the Northgate Customer Service Center (see the “How to Contact Us” Section below) or by following the instructions in the form of the communication you received, as described below: 

  • Emails: To opt out of receiving marketing materials via email, use the method provided in the emails or contact the Northgate Customer Service Center.
  • Printed Materials: To opt out of receiving printed marketing materials at your postal address, such as catalogs, flyers, or postcards, contact the Northgate Customer Service Center.
  • Voice Messages: To opt out of receiving voice messages by telephone, you may follow the instructions stated in the pre-recorded voice message or contact the Northgate Customer Service Center.
  • Text Messages: To opt out of receiving text messages or for more information about Northgate’s mobile marketing, refer to Northgate’s Mobile Marketing Terms and Conditions. 

CHANGES TO THIS POLICY

Northgate will notify you of any changes to this Privacy Policy by posting a modified version of this Privacy Policy on its websites and indicating the date it was last modified (i.e., the effective date). Northgate encourages you to visit its websites periodically to view the latest version of this Privacy Policy. 

HOW TO CONTACT US

Please contact the Northgate Customer Service Center by mail, email, or telephone, if you have any questions, comments, or concerns about this Privacy Policy or privacy-related comments or questions: 

Email: Privacy@NorthgateMarkets.com 
NORTHGATE GONZALEZ, LLC
Attn: Northgate Customer Service Center
1201 N. Magnolia Avenue
Anaheim, CA 92801
Phone: (888) 672-9832